On October 17. 2016 the FDIC released revised interagency examination procedures that reflect the Department of Defense’s (DOD) 2015 amendments to the implementing regulations of the Military Lending Act of 2006 (MLA) and its August 2016 interpretive rule that provides guidance on certain questions received regarding compliance with the MLA rule.

During early examinations, examiners will evaluate financial institutions’ compliance management systems and overall efforts to come into compliance. Specifically, examiners will consider an institution’s implementation plan, including actions taken to update policies, procedures, and processes; its training of appropriate staff; and its handling of early implementation challenges.